Making Safety Data Sheets

November 1999
Douglas Mowat, Chemical Exchange Directory S.A.

Previous Focus and Editorial articles have discussed legislation on working
with Chemicals and Hazardous Substances in Europe. This article deals with a
practical example and concerns making Safety Data Sheets (SDS) for chemicals.

The SDS has a very important role in the chemical market. It is the simplest
way for suppliers and their customers to exchange essential safety and
environmental information. A well constructed SDS reflects the image of the
supplying company, conveying an impression of competence and helps to build
confidence between the parties. All suppliers of hazardous substances and
preparations in the European Union are obliged to make SDS available for these
products. In addition, many companies have SDS for all of their products, even
those which are not classified as dangerous as their customers regularly ask for
an SDS for everything.

Even when a supplier has SDS exist for most of his products, there are still
many cases when a new SDS has to be made. Typical examples are for new products or
more often for new mixtures. Often, the SDS is needed quickly and the safety
specialist has to find reliable information with the minimum delay.

Making an SDS is a specialised subject, but fortunately there are good sources
of assistance for both experienced and inexperienced personnel. The basic
requirements on the contents of an SDS are published in European Directives
91/155/EEC and 93/112/EEC, both of which can be found on SilverPlatter's OSH-CD
product, as well as other guidance such as Safety data sheets for substances
and preparations dangerous for supply. The 16 Sections of the SDS are as
follows:

IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND THE COMPANY/UNDERTAKING

COMPOSITION/INFORMATION ON INGREDIENTS

HAZARDS IDENTIFICATION

FIRST AID MEASURES

FIRE-FIGHTING MEASURES

ACCIDENTAL RELEASE MEASURES

HANDLING AND STORAGE

EXPOSURE CONTROLS / PERSONAL PROTECTION

PHYSICAL AND CHEMICAL PROPERTIES

STABILITY AND REACTIVITY

TOXICOLOGICAL INFORMATION

ECOLOGICAL INFORMATION

DISPOSAL CONSIDERATIONS

TRANSPORT INFORMATION

REGULATORY INFORMATION

OTHER INFORMATION

The most important step is deciding if the product has dangerous properties
which require it to be classified, both for supply and for transport. This may
require the use of special labels and symbols along with Risk Phrases and Safety
Phrases.

The EU has published a list of dangerous substances for supply, often referred
to as Annex 1 (of Directive 67/548/EC), for which classification and labelling
requirements are pre-defined. The Hazards Identification in Section 3 of the SDS
and the Legislation Information in Section 15 are normally derived from the
information in Annex 1. A full list of these dangerous substances is in the
EINECS-Plus product, jointly published by SilverPlatter and the European Union
Publications Office. The remaining Sections of the SDS are then completed by
taking into account the dangerous properties, flammability, toxicology and
environmental properties etc.

When a product is not listed in Annex 1, the supplier must still make sure that
it is permitted to be sold in the EU market and that it does not have properties
which require a hazardous classification. The first step is to ensure that the
substance or the ingredients of a mixture are existing substances on the EU
market. This information can be found in the EINECS lists, (available in
EINECS-Plus). If it is not on the EINECS list, the substance will have to be
notified to a competent authority in the country where the product will be sold, a
process which can be both costly and time consuming. Placing unlisted products on
the market can result in significant penalties.

Assuming the substance is in EINECS, the next step is to decide if it needs to
be classified. This requires knowledge of the classification procedure. The EU
Substances Directive, 67/548/EC (and its subsequent amendments) contains several
Annexes to assist with this. Annex VI is a guideline on classification of
substances, and Directive 88/378/EEC and its subsequent amendments is the
equivalent for mixtures. Full texts of both these Directives are included in
EINECS- Plus as well as graphics which should be used in datasheets and labels
plus useful lists of definitions of Risk and Safety phrases.

The acute toxicity, ecotoxicology and flammability properties of the product
must be know to be able to decide if classification is necesasary. In the ideal
situation, test reports are available, and the procedure is relatively simple.
However, if there is no test data, the supplier has to find other sources, or
initiate testing.

The RTECS databank from the US NIOSH Agency contains toxicology information on
more than 100,000 substances and is one of the best recognised sources of such
data. The HSDB databank from the US National Library of Medicine also contains
toxicity data but in addition has, flammability (flash points), some ecotoxicology
information and also safety guidance for handling and storage. Both RTECS and HSDB
are on SilverPlatter's CHEM-BANK product and the information is updated regularly.

Using data from the above sources, it is possible to complete sections 3, 4, 5,
6, 7, 8, 10, 11, 12 and 15 on the SDS. Sections 1, 2 and 9 are dependent on the
supplier and the product. The remaining Sections, 13 and 14 again require
specialist knowledge. Section 13 concerns the safe disposal of the product and its
packaging. Information to assist in completing this section can be found in
SilverPlatter's Environment Plus product which contains the full text of the
environment related Directives of the Council of the European Communities plus
other authoritative advice and guidance. For Section 14, it is necessary to
consult the UN Recommendations on the Transport of Dangerous Goods, or the more
detailed regulations for road (ADR), Rail (RID), ocean (IMO) or air (ICAO/IATA).

Using data from these products, it is possible to make a good English language
SDS following the 16 section European Union format.

The above text is an illustration of how the SilverPlatter Health & Safety
Publishing Group's product range can help chemical suppliers in producing safety
data sheets.

The products mentioned in this article are available for a free trial.